Section 144C limitation bars delayed final assessment; TPO cannot resume proceedings after DRP directions.

Section 144C creates a mandatory, time-bound sequence for draft assessment, DRP objections and final assessment, and the Assessing Officer must complete the assessment in conformity with DRP directions within the prescribed period. Once an order under Section 92CA(4) is made, the TPO's role ends and the process does not permit renewed TPO proceedings after DRP directions. Because the final assessment was framed beyond the statutory limitation, it was held invalid and the challenge by the Revenue failed.

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Issues: Whether the assessment order framed after the statutory period prescribed under Section 144C(13) of the Income-tax Act, 1961 was invalid, and whether the TPO could resume proceedings after the DRP had issued its directions.

Analysis: The statutory scheme under Section 144C treats the draft assessment, objections before the DRP, and the final assessment as a time-bound sequence. Once the DRP issues directions, the Assessing Officer is bound to complete the assessment in conformity with those directions within the stipulated period. The role of the TPO ends after the order under Section 92CA(4) has been made, and the process does not contemplate renewed TPO proceedings after the DRP directions. Applying the earlier binding view on the same question, the delayed final assessment was contrary to the mandatory timeline.

Conclusion: The assessment made beyond the prescribed limitation was invalid, the appellate challenge failed, and the decision was against the Revenue and in favour of the assessee.

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